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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 34 of 37 the defense had substantial reason to believe that Epstein did not start living in the 71* Street townhouse until the beginning of 1996. Had property records for the 71° Street townhouse been available, they could have rebutted Jane’s testimony and challenged the accuracy of her recollection. Similarly, when Jane testified about her trip to Epstein’s ranch in New Mexico when she was “15 or 16,” she recalled staying at a “giant ranch sort of in the middle of nowhere ... [which] seemed very empty on the interior.” Tr. 321. From her description, it is clear that Jane was referring to the large ranch house that Epstein constructed on the property, and not the triple- wide trailer where he stayed while the large house was under construction. The defense had significant reason to believe that the large ranch house was not completed until the end of the 1990s, when Jane would have been closer to 18 or 19 years old. But because property records showing the dates of construction were not available, the defense could not challenge Jane’s recollection with contrary documentary evidence. E. Deceased Witnesses Finally, in the over 20-year period that elapsed from the time of the charged conduct to the time of trial, numerous potential witnesses who could have provided evidence contradicting the government’s proof had died. In addition to the ones already mentioned in our previous filings, the following individuals, among others, were no longer available to the defense: e Alberto Pinto and Roger Salhi — Mr. Pinto and Mr. Salhi were architects who built, renovated, and decorated many of Epstein’s residences, including the house in Palm Beach, the New York residence, and the ranch in New Mexico. The defense believes they could have established (i) when Epstein moved into the 71“ Street townhouse and what it looked like inside over the relevant time period, (ii) when the large ranch house was built, and (iii) that the Palm Beach residence was being renovated for almost a year in the mid-1990s and that Epstein had to move into a rental house during renovation. All of this evidence would have cast significant doubt on Jane’s recollection of events. 29 DOJ-OGR-00008958